Regarding the modifications made to the cabinets: if a new accessory is used to display goods in the cabinet (for instance extra podium of promotion stands), initiated by the end customer (supermarket), who is responsible for the new label?

To ensure the conformity and allow MSAs verifications, the manufacturer’s product documentation, EPREL declaration, Energy Label, CE declaration, sales order, and associated invoices, must relate to the specific product as it is placed on the market. This documentation shall include all the components/accessories influencing the EEI of the specific unit at the time of placing on the market.

The product modifications done after the placing on the market do not alter the energy label originally supplied by the manufacturer.

Why don’t you make it mandatory to fit doors to all refrigeration cabinets

The European Ecodesign and Energy Labelling Regulations do not prescribe any technical solution or product feature. However, The Ecodesign sets the minimum energy efficiency requirements and creates a selection of products according to their energy performance and the energy labels will drive the market to privilege the most efficient products with the best energy class. This will be the main driver of innovation.

What are the requirements for where the energy labeling should be placed on the refrigeration equipment? Is it a demand that customers in the stores should be able to see the energy labeling?

The energy label must be clearly displayed in any point of sale of the refrigerating appliance with direct sales function, such as showrooms, trade fairs, online sales, etc., i.e. wherever the potential cabinet buyer may consider purchasing the appliance itself.

Regarding the position of the label, there is no precise requirement for the position but the fact that it shall be clearly visible at any time for the client.

There is no obligation for food retailers to display the energy label in their stores.

Please clarify what is definition 'placed in the market'? is it when cabinet is sold or when delivered?

For the purposes of Union harmonization legislation, a product is placed on the market when it is first made available on the EU market. This operation is reserved to the manufacturer or importer, who are the only economic operators placing products on the market.

When a manufacturer or importer supplies a product to a distributor or end user for the first time, this operation is always referred to in legal terms as 'placing on the market'. Any subsequent operation, for example from distributor to distributor or from distributor to end user, is referred to as 'making available'. For our kind of products, the moment in time when the product is placed on the market is when there is the transfer of property with the client, i.e. which generally is considered the invoice date.

Please clarify: how different configurations are handled? Do all configurations need own label? That will lead to tens of thousands of labels

With reference to the requirements and obligations for the supplier stated in the Regulations, any product that differs from another for basic characteristics, product temperature class, TDA/volume or energy consumption must be labeled individually.

However, the Eurovent Interpretation Guideline introduces the “cluster” approach, i.e. a set of cabinets identified as one model for the purposes of Ecodesign, Energy Labelling and EPREL. Within some limits, manufacturers can group different models into one model, which is representative of the highest EEI (i.e. worst score) of the listed family.

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